Date:    08/16/2000  1:48 PM

Subject: S7-13-00

The proposed SEC scope of services rule would prove to be devastating to 
accounting firms of all sizes throughout this country.  It does not take any 
imagination to also recognize the ripple effect such a rule could impose on 
all current CPA services, their clients and the individuals that are employed 
by such firms.
     
It is difficult to understand why the SEC would propose such a sweeping 
change in the scope of services of accounting firms without offering any 
compelling evidence citing the need for such a change.  I am not aware of any 
data, studies or even any hint from the SEC that such a change was necessary.
     
Why the rush to judgment?  Why not allow time for both the SEC and the 
accounting profession to offer proper evidence regarding this issue.  
     
Without some rational change in either the SEC proposal or the time allowed 
to consider the proposal, this would appear to be a "unilateral decision by 
the SEC to attempt to impose its will on any number of business without the 
statutory authority to do so."
     
This effort by the SEC and how it is packaged gives one reason to wonder if 
this is politically motivated.  On its face this is just very difficult to 
understand.
     
I am a CPA.  I am not affiliated now nor have I ever been affiliated with a 
CPA firm.  I am not required to write this letter but I am personally 
compelled to do so because of the reasons cited above.
     
Sincerely,
     
Robert W. Freeman, Sr.,  CPA